Related Commentary  Related HMRC Manuals

31(1)  For the purposes of corporation tax, subsection (2) has effect as respects the disposal by a company (“the disposing company”) of shares in, or securities of, another company if–

(a)arrangements have been made whereby the value of those shares or securities, or any relevant asset, is materially reduced,

(b)the main purpose, or one of the main purposes, of the arrangements is to obtain a tax advantage, and

(c)the arrangements do not consist solely of the making of an exempt distribution.

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